Baker v. Alabama

Background

The case involves a person sentenced in Alabama who sought review of a state-court judgment. The Court granted the person’s motion to proceed without paying fees and granted the petition for review. The Supreme Court vacated the Alabama judgment and returned the case to the Court of Criminal Appeals of Alabama for further consideration in light of the Court’s decision in Montgomery v. Louisiana.

Reasoning

The Court’s action was procedural: it held the petition pending Montgomery, then vacated the lower-court judgment and sent the case back so the state court can reconsider the claim under Montgomery. The majority did not resolve whether the person is entitled to retroactive relief; it only instructed the lower court to reexamine the case in light of the new ruling.

Real world impact

Practically, the decision requires Alabama courts to revisit this specific sentence and similar cases to see if Montgomery changes the result. The Supreme Court’s disposition is not a final determination that the person gets relief; the state court must decide that question. On remand, the state court may consider state-law grounds, whether the person waived claims, or whether the sentence truly qualifies for the kind of relief Montgomery addresses.

Dissents or concurrances

Justice Thomas, joined by Justice Alito, wrote separately to emphasize that the Court’s vacatur and remand do not express any view on entitlement to relief and do not decide issues like state-law bars, forfeiture or waiver, or whether the sentence is a mandatory life-without-parole sentence.